[CPEO-MEF] Pentagon Environmental Proposals

[joelf@cape.com]

Dear Folks,

The proposed change in CERCLA by the Pentagon is obscure to the point 
of being deceptive. However, the intent is very simple: Pollution of 
an "operational range", including the groundwater under it, by 
"explosives" or "constituents therein", would henceforth be permitted 
unless such pollution extended or migrated off the "operable range". 
See quoted sections below.

What this means, is that the military could fire artillery shells and 
rockets (whether or not such weapons were obsolete relative to any 
legitimate modern threat to the U.S. population) into an area 
up-stream of public drinking water supply wells, polluting 
groundwater flowing towards these wells.

Worse still, it appears that the proposed changes in environmental 
legislation would prevent any investigation of the groundwater under 
an operable range to determine whether training practices have caused 
the pollution of groundwater flowing towards a source of public 
drinking water.

You may think that the problem just analyzed poses only a 
hypothetical threat to the interests of U.S. citizens. Not so. It is 
easy to show that the Pentagon proposal is a tactical response to the 
actual conditions existing on Cape Cod.

Because of EPA mandated groundwater studies at the Massachusetts 
Military Reservation (and an ordered halt to any firing of rockets, 
mortars, and artillery), it was learned that explosive compounds, 
including RDX and perchlorates, had contaminated the underlying 
groundwater and were flowing towards supply wells and surface water 
bodies in the towns of Sandwich and Bourne. Monitoring wells 
subsequently were placed on the base boundary and as "sentinels" 
around four Bourne supply wells. Sequentially, perchlorates were 
detected at the base border, at the sentinel wells and in the supply 
wells, which have been shut down.

The town of Bourne, and Cape Cod as as whole, faces a crisis as cruel 
as that which could be caused by any enemy. Coupled with the current 
draught, the loss of supply wells from military pollution in Bourne, 
Falmouth  and Sandwich, has produced an acute and long-term shortage 
in water for drinking, cooking, and bathing. Moreover, since records 
have been kept, the area has experienced an extreme excess in 
age-adjusted cancer rates.

What follows is the actual text of the Pentagon's proposal:


"(b)(1) Definition of Release. - (1) The term 'release,' as used in the
Comprehensive Environmental Response, Compensation, and Liability Act of
1980, as amended (42 U.S.C. 9601 et seq.), includes the deposit off an
operational range, or the migration off an operational range, of any
explosives, unexploded ordnance, munitions, munitions fragments, or
constituents thereof.

"(2) The term 'release,' as used in the Comprehensive Environmental
Response, Compensation, and Liability Act of 1980, as amended (42 U.S.C.
9601 et seq.), does not include the deposit or presence on an
operational range of any explosives, unexploded ordnance, munitions,
munitions fragments, or constituents thereof that are or have been
deposited thereon incident to their normal and expected use.

For a healthier and more peaceful world,

Joel Feigenbaum
--
Joel Feigenbaum
24 Pond View Drive
E. Sandwich MA 02537
(508)-833-0144

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